AceAge Privacy Policy

Privacy Statement

AceAge Inc. (“AceAge”), located at 835 Harrington Court, Burlington, ON, Canada, is committed to protecting the privacy rights of all persons with whom it deals.  AceAge will take every step to maintain the confidentiality of your personal information.  This Privacy Policy applies to your use of AceAge’s Karie product and this Privacy Policy informs on AceAge’s collection, use and/or disclosure of an individual’s personal information.

Accountability

AceAge is accountable for all personal information under its care and control.  Within AceAge we have appointed a Privacy Officer in case you have any questions about this Privacy Policy.  The Privacy Officer can be reached as follows: by email at privacy@aceage.com or by mail at AceAge Inc., 835 Harrington Ct, Burlington, ON, Canada L7N 3P3, Attn: Privacy Officer.  Any questions relating to AceAge’s handling of personal information should be directed to the Privacy Officer.

Security

AceAge has taken appropriate technical and organizational measures to protect your personal data against loss or against any form of unlawful processing.  AceAge has established an information security policy and taken physical, organizational, and electronic measures with due observance thereof.  Your data is transmitted via secure connections over the internet.  We contractually commit third parties who are engaged in the management and development of our platform and or products to respect the confidentiality of your personal data, and to uphold the same standards as AceAge.

Purpose and Personal Information Collected

AceAge’s products organize, schedule, and deliver pills to ensure that individuals take their medication at the right time through the use of (amongst other things) a medication delivery device, a mobile app companion to that device and our website (the “Services”).  AceAge’s Services are used by individuals (“users”) who decide to operate an AceAge product.

AceAge may use personal information notably in the following ways.   In each case, AceAge identifies the basis on which AceAge relies to use your personal information:

  • to provide its Services: Applicable legal basis: contract performance
  • to provide product information: Applicable legal basis: contract performance, legitimate interest, consent
  • to open, maintain and process credit card transactions: Applicable legal basis: contract performance, legitimate interests (to ensure that AceAge is paid for its services), legal requirement
  • to administer and process customer surveys, special promotions and other marketing activities: Applicable legal basis: legitimate interests, consent
  • to investigate legal claims or comply with our legal obligations: Applicable legal basis: legal obligation, legitimate interest

As a result, personal information can be collected when you use the Services.  This can include your name, age, address, the medications which you have been prescribed, when you are required to take medication and when you actually take them, medical conditions which you may have, billing information and credit card information.

If you use AceAge’s website (the “Website”), your IP address, your computer’s operating system, the browser type and language are automatically collected each time you use the Website.  Moreover, the identity of the website you came from will also be collected, as will your web request and the date and time of your visit and the site pages visited.  Other information such as your name, address, and email address (“contact information”) is collected in order to allow us to administer the Website, to identify and contact users and in order to conduct Website maintenance.  For audit and other internal and administrative purposes AceAge may also keep a record of all information you contribute to the Website.

Recipients of your Personal Information

Your personal information may be provided to AceAge’s service providers and partners, such as pharmacists, in order to provide you with a seamless user experience and to improve the quality of our services.  AceAge will not disclose your personal information to other people or non-affiliated companies, except in the limited circumstances described in this Privacy Policy or with your consent.  When AceAge discloses your personal information to its service providers, AceAge takes reasonable actions to ensure that the same rules apply to our service providers as they apply to AceAge.

AceAge does not rent or sell personal information to other companies or individuals.  AceAge may share aggregated non-identified information with other companies.  AceAge may also use your personal information on an aggregated, non-identifiable basis for research and development purposes.  AceAge may also provide personal information to third parties who may provide services on AceAge’s behalf such as responding to customer inquiries, processing data, conducting special promotions, and marketing activities and other administrative functions.  In all instances, AceAge will only provide personal information to third parties on an “as needed” basis and provided that such third parties agree to be bound by agreements that we have put in place to guarantee the safety of your personal data.

International Transfer of Personal Data

Your personal information may be stored and processed in any country where AceAge has facilities, partners or uses third party service providers.  AceAge will take all reasonable steps to protect your personal information in accordance with our internal rules and regulations.  Some of AceAge’s establishments and/or partners being located outside the European Union and/or Canada, personal data collected may be transferred to countries outside the European Union and/or Canada, whose legislation on the protection of personal data differs from that of the European Union and/or Canada.  In the event that the recipient country or countries would not ensure a level of data protection equivalent to that of the European Union as recognized by an adequacy decision, AceAge undertakes to take all appropriate guarantees on the basis of appropriate safeguards such as standard contractual clauses or binding corporate rules in order to safeguard the transfer of personal data.

Limits for Collecting, Using, Disclosing and Retaining Personal Information

AceAge limits the amount and type of information collected to that which is necessary to meet the purposes described above.  AceAge undertakes to keep all personal information it collects strictly confidential.  AceAge will only retain personal information for the duration of its intended use or as otherwise required by law.  Thereafter, all personal information that does not have a specific purpose or that no longer fulfills its intended purpose will be destroyed in a secure fashion.

Links to Other Websites

AceAge’s Website may contain links to other websites of interest.  However, once you have used these links to leave the site, you should note that AceAge does not have any control over that website.  Therefore, AceAge cannot be responsible for the protection and/or privacy of any information that you provide while visiting such sites.  Also, please be advised that such websites are not governed by this Privacy Policy.  You should exercise caution and review the Privacy Policy of any website that you enter via the AceAge website.

Safeguarding Personal Information

AceAge respects individual’s privacy and will protect that personal information as vigorously as possible.  AceAge stores personal information in electronic and physical files that are secure and to which access is restricted.

Accuracy of Personal Information

AceAge also makes every effort to keep all personal information it holds, including contact information and financial information, accurate, complete, and current.  After verification, AceAge will update any changes to personal information when received from you through the Website or otherwise.  If AceAge holds personal information about an individual which can be established by the individual to be inaccurate, AceAge will take reasonable steps to correct it.

Consent

By using the Karie product you agree to the fact that your data is used for the purposes described above.  Should you choose, at any time, to stop using the Karie product, the collection and use of your personal data will stop.  Your personal data will be deleted according to our internal procedures and envisioned retention terms.  If AceAge wished to continue using your personal data, it will seek consent for such new use.

Exercise of Rights

Regarding your personal information, you have the following rights:

  • Access:  You are entitled to ask if AceAge is processing information and, if any, request access to personal information.  This enables the individual to receive a copy of the personal information AceAge holds and certain other information about him or her; and
  • Rectification:  You are entitled to request that any incomplete or inaccurate personal information AceAge holds be corrected.

Where applicable, you have also the following rights:

  • Deletion:  You are entitled to ask AceAge to delete or remove personal information in certain circumstances.  There are certain exceptions where AceAge may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with claims;
  • Restriction:  You are entitled to ask AceAge to limit the processing of certain personal information, for example to establish its accuracy or the reason for processing it;
  • Portability:  You may request the portability of certain personal information to another party;
  • Objection:  You may challenge when AceAge processes personal information based on a legitimate interest (or those of a third party) or for direct marketing purposes.  However, AceAge may be entitled to continue processing information;
  • Automated decisions:  You may contest any automated decision made where this has a legal or similar significant effect and ask for it to be reconsidered;
  • Withdraw Consent:  Where AceAge processes personal information with consent, you may withdraw your consent; and
  • Complaint:  You have the right to lodge a complaint within the relevant national data protection authority.

For security reasons and to avoid any fraudulent request, you may be required to provide proof of identity with the request.  After the request has been processed, this receipt will be destroyed.  When you make your request, you will receive instructions from AceAge on how to send us proof of identity.  AceAge will respond to your request within 30 days of receiving your request.

Questions

If you have any questions regarding the personal information held by AceAge, you should, in writing, contact AceAge’s Privacy Officer.  AceAge will respond to any written requests within 30 days of receiving written notice.  AceAge will keep records of enquiries and/or objections and will document their resolution.  AceAge will conduct all investigations in a timely, fair and impartial manner.

European Data Protection Representative

If you currently reside in the European Economic Area (EEA) or you have been residing in the EEA at the time that your personal information was processed by AceAge, you may contact our Data Protection Representative (DPR) with your request or inquiry regarding the GDPR.  Our DPR resides in the European Union.  When your request or inquiry is received, our DPR will investigate and reply to you within a period of 30 days.  If our response is unsatisfactory you may reply to us directly or notify the relevant data protection authority (for example in your home country) or refer the matter to a court of competent jurisdiction.

Contact details AceAge DPR:

DPO Consultancy B.V.
Australiëlaan 12a
5232 BB ’s-Hertogenbosch
Email: dpr@dpoconsultancy.nl

Protection of Personal Information for Children

AceAge Services are not intended for any minor individual.  If you are a minor under the laws applicable to your place of residence, please do not provide AceAge with any personal information without the express consent of a parent or guardian.  AceAge does not voluntarily collect personal information from minors.  If you are a parent or guardian and you know that your minor child has provided AceAge with personal information, please contact AceAge.  If AceAge learns that it has collected personal information from a minor without verification of parental consent, AceAge will take steps to remove that information from its servers.

Changes to the Privacy Policy

AceAge reserves the right to modify or supplement this Privacy Policy at any time.  If AceAge makes a change to this Privacy Policy, AceAge will post such changes on the Privacy page of the Website.  AceAge will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your personal information for purposes other than those for which it already has a valid processing ground.

 

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